Air transport profits taxed only in the enterprise's State; related interest treated as transport income under treaty. Profits from operating aircraft in international traffic are taxable only in the enterprise's State, including profits from pools, joint businesses or international operating agencies. This exclusivity also covers offices or agencies in the other State only for activities directly connected with aircraft operation. Interest related to aircraft operation is treated as profits from that operation and Article 12 on interest does not apply. 'Operation of aircraft' includes carriage of passengers, mail, livestock or goods, ticket sales for others, incidental leases and other directly connected activities.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Air transport profits taxed only in the enterprise's State; related interest treated as transport income under treaty.
Profits from operating aircraft in international traffic are taxable only in the enterprise's State, including profits from pools, joint businesses or international operating agencies. This exclusivity also covers offices or agencies in the other State only for activities directly connected with aircraft operation. Interest related to aircraft operation is treated as profits from that operation and Article 12 on interest does not apply. "Operation of aircraft" includes carriage of passengers, mail, livestock or goods, ticket sales for others, incidental leases and other directly connected activities.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 
Join Channel
TaxTMI 
